CONNELL, District Judge.
This action arises on a suit for a refund of a deficiency income tax for the year 1949 in the amount of $17,642.13, and interest assessed thereon in the amount of $2,357.28, paid by this plaintiff under protest in July, 1952. The sole basis for the deficiency assessment was the disallowance of a tax deduction of about one-half of the $81,301.56 compensation paid to Mr. J. L. Berger, the corporation's Vice-President and Treasurer, accrued by...
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